Mining for insights from transfer pricing leaders

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Mining for insights from transfer pricing leaders

Taxpayers should not pass the opportunity to get answers from influential transfer pricing officials in September.

The importance of transfer pricing as a reputational issue means it is critical that taxpayers have the right policies to enable them to comply with their obligations on the topic around the world.

Businesses need to understand national rules on related-party transactions, develop the best ways - including having the right technology - to adhere to them and maintain an awareness of how the rules might be changed or added to in the future.

Their knowledge and understanding of national transfer pricing laws and rulings in a given jurisdiction allows tax departments to make the right decisions on subjects, such as the financing of a subsidiary, the location of an R&D project, the suitability of an advance pricing agreement, the correct methodology when documenting a transaction or the approach to take when faced with an audit, as well as monitor tax risk.

Australia, Canada and the UK are three jurisdictions that have proposed amendments or gone ahead with rewrites to their transfer pricing regimes in the last few months. Advance pricing agreements are now possible in Hong Kong and India - though no guidance has been published in that country yet. And concepts such as management fees and location savings are getting wider exposure around the world.

These are important developments that require careful thought and analysis, particularly at a time when transfer pricing rules and regulations are developing rapidly all over the world, judges are getting the opportunity to interpret existing laws, sometimes in unforeseen ways, and tax administration is becoming more and more international, with ideas and tips being passed back and forth by revenue authorities all the time.

The Ask the Authorities panel at September’s Global Transfer Pricing Forum, hosted by International Tax Review and TPWeek, offers executives a unique platform to get answers to their questions about related-party matters.

Officials from three countries will field queries about all aspects of transfer pricing during the 75-minute discussion at 1.30pm on September 25. The agenda covers documentation, legal certainty, advance pricing agreements, joint audits and alternative dispute resolution, though the participation of Michelle Levac, of the Canada Revenue Agency, who chairs the OECD’s Working Party No 6, makes it likely that the multilateral organisation’s most recent projects on intangibles and restructuring will also come up.

The other panellists are Eric Lesprit, the head of the APA team at the French Tax Administration and Peter Steeds, who took over as head of transfer pricing at HM Revenue & Customs in the UK last October.

more across site & shared bottom lb ros

More from across our site

Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Sponsored by Deloitte
Sameer Nurmohamed, partner, Deloitte Legal Canada
Sponsored by Deloitte
George Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)
The recent spree of firm mergers and acquisitions proves that geographic scale is the name of the game
The big four spin-off firm becomes Taxand’s second UK member; in other news, Haynes Boone launched a UK tax practice
Sponsored by Deloitte Luxembourg
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
Stephanie Pantelidaki’s economic expertise will give Norton Rose Fulbright’s other teams ‘extra firepower,’ she says
Sponsored by MFA Legal & Tech
Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
Sponsored by McCarthy Tétrault
Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance
Gift this article